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   September/October 2016  
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Asia-Pacific Tax Bulletin
This free e-mail service informs you about the contents of the forthcoming edition of Asia-Pacific Tax Bulletin.

Issue No. 5 - 2016 of the Asia-Pacific Tax Bulletin is now available online.

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Number 5 - 2016 contains the following:



Country-by-Country Reporting: Another Step in Global Tax Transparency

Les Nethercott and Livia Gonzaga

In this article, the authors consider the Country-by-Country reporting requirements of Action 13 of the BEPS Action Plan and the Australian legislation in respect of it. The article gives an overview of the practical aspects of the reporting requirements in relation to the reporting period, availability of information, reporting responsibility, the role of advisers, materiality, consistency and corporate strategy.


A Strategic Consideration of China’s Measures in Response to FATCA

Jiang Yuesheng

This opinion piece, from the perspective of a senior Chinese tax official, sets out the author’s views on the impact of FATCA upon China, and the manner in which the BEPS action plans assist the United States in achieving its FATCA goals. The author also presents proposals for actions which China could take to assert its national interests in the new order of taxation of cross-border income.


AMP Expenditure, Location Savings and Guarantee Fee Aspects of Transfer Pricing

Anis Chakravarty and Shuchi Ray

This article examines the AMP expenditure, location savings and guarantee fee elements of the transfer pricing debate. In particular, the authors discuss the three components in the context of United States and Indian jurisprudence, various government pronouncements, recent BEPS developments and changes to the OECD transfer pricing guidelines.


The Canon of Ejusdem Generis – A Useful Servant or a Bad Master for the Pakistani Income Tax Statute?

Najeeb Memon

This article deals with the application of ejusdem generis - a canon of statutory interpretation - in Pakistan, a jurisdiction without codified canons of interpretation. The author examines the difficulties faced by Pakistani superior courts in applying the ejusdem generis doctrine in the context of the Income Tax Ordinance 2001. The article also examines various enumerative and exhaustive definition provisions of the Ordinance for applicability of the ejusdem generis principle to ascertain the scope of the defined terms. The author finds that the courts in Pakistan have been able to use, albeit with some difficulties, the ejusdem generis rule to determine the intent of provisions in the Ordinance. However, he concludes that legislature needs to be aware of canons of interpretation when drafting enactments, to ensure that their real purpose is secured.


New Zealand

High Court Denies Disclosure of Documents Exchanged under New Zealand-Republic of Korea Tax Treaty

Kevin Holmes

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